Effective as of 31 January 2023, Ukraine introduced a new set of personal sanctions against 182 Russian and Belarusian legal entities, mainly transport and leasing companies as well as chemical enterprises, and 3 individuals — citizens of the Russian Federation.[1] The sanctions package, according to the President of Ukraine Volodymyr Zelenskyy, is aimed at companies involved in transporting Russian military equipment and soldiers.

The Decision imposes extensive sanctions, including asset freeze; ban on trade operations; ban on transit of resources, flights and transportation within the territory of Ukraine; suspension of the performance of economic and financial obligations; restriction on the exit of capital from Ukraine; prohibition on participating in privatization and lease of state property, as well as public and defense procurement; ban on securities transactions; termination of trade agreements and joint projects; and prohibition on concluding contracts and executing transactions. Among others, the sanctions affect the following categories of persons:

The full lists of legal entities and individuals subject to sanctions are set forth in the annexes to the Decision. Any party dealing with persons on the sanctions lists must carefully assess the exact scope of the sanctions imposed and the implications of dealing with such entities and individuals.

[1] Presidential Decree No. 50/2023 dated 28 January 2023 “On the Decision of the National Security and Defense Council dated 28 January 2023On Imposing and Amending of Personal Special Economic and other Restrictive Measures (Sanctions)”,” effective from 31 January 2023 (“Decision“).


Hanna Shtepa is a Counsel heading the International Commercial & Trade (ICT) practice in the Kyiv office of Baker McKenzie. The practice is ranked Tier 1 by Legal 500 EMEA. She specializes in international trade restrictions, economic sanctions and export controls compliance, structuring international supplies of goods and services, anti-dumping investigations, public procurement regulations, trade and general compliance, legal regime and restrictions related to temporary occupied territories and business operations during the military state. She also has extensive experience in project finance, focusing on renewable and conventional energy, financial restructuring, sovereign and municipal finance, nuclear liability. Hanna is ranked as Next Generation Partner for International Trade and Energy and recommended as a Rising Star in Banking, Finance and Capital Markets by Legal 500 EMEA 2020-2022. Ms. Shtepa holds her LL.M. in International Commercial Arbitration Law from the Stockholm University, Stockholm, Sweden.